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Priority Based Exams Company has not participated in Phase 1 Vessel has not been examined High Priority Vessel Company participating in Phase 1 Vessel has not been examined Low Priority Vessel Company participated in Phase 1 Vessel has been examined Non-Priority Vessel Note – Deficiencies identified during priority based exams (not IIEs) will be publically available through PSIX

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UTV Exam Form Changes from old form – New Requirement for UTVs guidebook – Changes to exam item locations/groupings – CEMS removed – Additional statuses on first page – Separate recommendations and deficiencies pages – New Instructions form

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UTV “C” School Yorktown, VA Paducah, KY Exportable s.asp s.asp

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NPRM Subchapter M – Comments Online or in writing Comments and related material must be submitted to the online docket on or before December 9, 2011 Identify comments by inserting Docket Number USCG in the “docket ID” box Federal eRulemaking Portal

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Applicability Applicability – All towing vessels (commercial, engaging or intending to engage in pulling, pushing, hauling along side or any combination thereof) Exceptions – Less than 26 feet, unless towing barges carrying dangerous or hazardous materials – Assistance towing – Vessels towing recreational vessels for salvage – Vessels transporting or assisting navigation of recreational vessels within and between marinas and marina facilities within a limited geographic area – Workboats operating exclusively in a worksite – Seagoing towing vessels > 300 GRT – Vessels otherwise inspected that “may perform occasional towing” – Public vessels – Vessels that surrendered COI and is laid up, dismantled or otherwise out of service – Propulsion units used to propel or control direction of a barge (controlled from the barge, not normally manned, not used as independent vessel)

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Certification All COIs issued by USCG (5 year validity) Options for certification – Annual USCG inspection – Towing Safety Management System (TSMS) with use of approved 3 rd parties Specify option when applying for each COI (may be different for each vessel) Drydock/Internal Structural Exam – twice in 5 years, no more than 36 months (for all vessels exposed to salt water more than 6 months per year)(once in 5 otherwise) UWILD option available 46CFR

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USCG Option Owner/Operator schedules with OCMI Annual inspection +/- 3 months of anniversary – Similar but less detailed than COI issue/renewal May include any tests or inspections deemed necessary to evaluate seaworthiness Deficiencies documented with timeframe on CG- 835 Periodic inspection (full) at +/- 3 months of 2 nd or 3 rd anniversary (takes place of annual)

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What is an approved 3 rd party? Organization approved by the USCG to carry out functions related to ensuring that TVs comply with the provisions of Sub M (audits, TSMS certificates, surveys, reports) Must be independent of the owner, managing operator and vessels they will be acting as 3 rd party for Must meet all the requirements of 46CFR139 Recognized classification societies (46CFR8) are prequalified 46CFR

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This chart shows the compliance timeline depicted in the proposed rule. The proposed rule phases-in the requirements to lessen the burden on the towing companies. After the final rule is issued, a company has two years to develop a TSMS if they utilize the TSMS option. The initial COI must be obtained within 4 years from the TSMS approval. Certain requirements for electrical and machinery systems, such as pilothouse alerter system and remote shutdown devices, were deferred until five years after the initial COI. Towing vessels moving oil or hazmat in bulk also have certain electrical and machinery requirements deferred until five years after the first COI.